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Preventing Financial Exploitation: Steps for Safeguarding Senior Investors

June 27, 2023

In honor of Elder Abuse Awareness Month, we're taking a look at FINRA's important senior investor protection efforts, including a look at FINRA Rules 2165 and 4512, the first uniform National Senior Investor Protection Standards.


On this episode, we hear from Associate General Counsel Alicia Goldin and Vice President and Associate General Counsel Jim Wrona where those rules stand today, explore some of the real-world scenarios in their application and provide tips for some of the tricky conversations that financial professionals might face in connection to their application.


Resources mentioned in this episode:

Rule 2165: Financial Exploitation of Specified Adults

Rule 4512: Customer Account Information

Episode 105: Essential Senior Investor Protection Tools

Reg Notice 22-31: Practices for Obtaining Trusted Contacts

“Investors in the U.S.: The Changing Landscape,” FINRA Foundation (December 2022)

Trusted Contact Resource Page

Trusted Contact Infographic

2023 Report on FINRA’s Examination and Risk Monitoring Program

2020 Ontario Securities Commission Protecting Aging Investors Report

Blame and Shame in the Context of Financial Fraud

IACP Successful Trauma-Informed Victim Interviewing

Senior Safe Act Webinar: Identifying and Reporting Suspected Exploitation


Listen and subscribe to our podcast on Apple PodcastsGoogle PodcastsSpotify or wherever you listen to your podcasts. Below is a transcript of the episode. Transcripts are generated using a combination of speech recognition software and human editors and may contain errors. Please check the corresponding audio before quoting in print. 


00:00 - 00:28

Kaitlyn Kiernan: In honor of Elder Abuse Awareness Month, we're taking a look at FINRA's important senior investor protection efforts, including a look at FINRA Rules 2165 and 4512, the first uniform national senior investor protection standards. On this episode, we're going to hear an update on where those rules stand today, explore some of the real-world scenarios in their application and provide tips for some of the tricky conversations that financial professionals might face in connection to their application.

00:28 – 00:37

Intro Music

00:37 - 01:08

Kaitlyn Kiernan: Welcome to FINRA Unscripted. I'm your host, Kaitlyn Kiernan. I'm pleased to welcome to the show today two individuals from FINRA's Office of General Counsel. Joining us for the first time is Associate General Counsel Alicia Goldin. And today, we are welcoming back to the show Vice President and Associate General Counsel Jim Wrona. Alicia and Jim, welcome to the show. So, just to kick things off today, can you start by introducing yourselves and telling us a little bit about your backgrounds and what you do at FINRA? Alicia, as a newcomer, maybe we can start with you.

01:09 - 01:29

Alicia Goldin: Sure. Thanks, Kaitlyn. Happy to be here. I'm in the Regulatory Practice and Policy Group where I focus on several areas, including Regulation Best Interest, Form CRS and senior investor protection. I recently joined FINRA from the SEC, where I worked in the Division of Trading and Markets for many years, and prior to that I was in private practice.

01:30 - 01:32

Kaitlyn Kiernan: Great. Thanks, Alicia. And Jim, how about you?

01:32 - 01:47

Jim Wrona: As you mentioned, I'm with FINRA's Office of General Counsel, just like Alicia. And as part of my work, I focus on senior investor issues, and I've been working in that area for about 20 years. So, it's something that's near and dear to my heart.

01:47 - 02:24

Kaitlyn Kiernan: Yes, the last episode we had you on was also senior protection issues. So, glad to have you back on this important topic. If you haven't already, I do encourage you to check out Episode 105 from last May with Jim on the FINRA Rules 4512 and 2165, which are two of FINRA's key investor protection rules. We have a link in the show notes if you need that. But Alicia, for those who haven't had a chance to hear that episode or maybe need a refresh before we dive in today, can you give us a quick overview of what those two rules are all about?

02:25 - 03:27

Alicia Goldin: At a really high level, we're going to talk about trusted contacts, and that comes from a provision in FINRA Rule 4512 relating to customer account information. And the rule requires broker-dealers to make reasonable efforts to obtain from all non-institutional customers the name and contact information for a trusted contact person. That's essentially someone that the broker-dealer can reach out to for a variety of reasons, including when there are concerns that the investor may be a victim of financial exploitation. And we do view this as a really important tool for protecting senior investors, but I want to emphasize that it's not limited to senior investors. A trusted contact person can be valuable for investors of all ages. We'll also talk about FINRA Rule 2165, which allows a broker-dealer to place a temporary hold on disbursements of funds or transactions if there's a reasonable suspicion of financial exploitation of a senior or other vulnerable adult.

03:27 - 03:50

Kaitlyn Kiernan: Great. Thanks, Alicia. Now, Jim, just to dig in more first on the trusted contacts component—in December, FINRA issued Regulatory Notice 22-31, which we'll also link to in the show notes. It provided some effective practices for firms looking to obtain a trusted contact from a customer. Can you give us some background on why we published that Notice?

03:51 - 04:48

Jim Wrona: We've now had several years of experience with the rule. There's been a lot of positive feedback when trusted contact information is available. It's been really critical in helping to stop financial exploitation of seniors. The immediate challenge for us is really the low uptake rates that we're seeing. So, the FINRA Foundation released a report back in December 2022 on investors in the United States that indicated 38% of respondents reported having authorized a trusted contact for their investment account. So, we wanted to learn why. And so, we spoke with broker-dealers, investor protection groups, other regulators. The purpose of the notice is threefold. So, first, to discuss the many benefits of having a trusted contact. Second, to highlight customer education resources, to explain what a trusted contact is and what it is not, and also to share effective practices.

04:49 - 05:10

Kaitlyn Kiernan: Admittedly, I am one of those people that is on the wrong side there. I just logged into my brokerage account recently and they asked me to add a trusted contact, but I was in a hurry, closed the thing and then I couldn't figure out how to add it later. So, what are some of the issues behind the low uptake? I'm sure there are some people like me who can't figure out how to add it, but are there other issues driving this?

05:10 - 06:15

Jim Wrona: So, first of all, I strongly encourage you to add a trusted contact, so please do that. I'm glad that your firm asked you. Yeah, so, we know that there are some firms that have prioritized this issue and they've been very successful at getting positive response rates. But to be frank, there's a level of commitment by firms that varies. So, at some firms there hasn't been enough emphasis on the importance of trusted contacts. At other firms, maybe they're not approaching it in the most beneficial way. We also understand there's a variety of reasons why customers are not opting to provide a trusted contact. So, for instance, we've heard there's misunderstandings of the role of the trusted contact. I think some customers have indicated that they believe that it grants power of attorney or other even greater authority to the trusted contact. There's concern about giving up autonomy or being perceived as needing help. There's privacy concerns that some customers have had, not wanting to share account information with family members or with third parties. And then, quite frankly, there's procrastination, which is the bucket that you might fall into.

06:15 - 07:08

Alicia Goldin: There's also some interesting research on this. A few years ago, in connection with its own proposed regulation concerning trusted contacts, the Ontario Securities Commission partnered with behavioral scientists to conduct research to understand the psychological, emotional and social factors that may influence an older investor's decision to appoint a trusted contact person. And their goal was to find ways to increase that likelihood. They identified a number of barriers, and Jim mentioned a few, but for example, optimism bias. That's the tendency to underestimate the likelihood of a negative event. Overconfidence, the tendency to think one's abilities are better than they actually are, avoidance of negative emotions and fear of losing independence. Their report, published in November 2020, is called Protecting Aging Investors Through Behavioral Insights.

07:09 - 07:26

Kaitlyn Kiernan: That's very interesting. So, there's definitely a lot of psychological factors here. So, you also mentioned procrastination. I know many of us can fall victim to that, including myself. How have some firms been successful in getting their customers to bite the bullet and name a trusted contact?

07:26 - 08:53

Jim Wrona: So, how you ask the question really matters, whether that's in conversation or on paper or electronic form. So, let's take a verbal conversation. So, if you ask, "Whom would you like to designate as a trusted contact?", that's probably going to be more successful than asking, "Would you like to designate a trusted contact?" It assumes the close. Or online what some firms do is they require an affirmative answer in the account opening agreement. So, the customer has to either provide the trusted contact info or affirmatively decline to provide the information. And this helps avoid customers just ignoring, rolling over the question altogether. And I think that not only how you ask, but the number of times you ask.

So, some firms will include a prompt for the registered rep. Every time the registered rep opens up information about the customer, there's a field and a prompt about trusted contact. "Has the customer provided trusted contact information? You should ask," so that it's always kind of top of mind when they're having those meetings with customers. Likewise, there can be a prompt for customers, so every time the customer logs on to their account information, there's a prompt about adding a trusted contact. So, these are all things that are pretty simple, but little changes make a big difference.

08:53 - 09:00

Kaitlyn Kiernan: Can you share some of that information on the importance of education and how to get customers to actually go ahead and add this contact?

09:00 - 10:16

Jim Wrona: Education really is key. Providing simple information about what a trusted contact is, and I think, even more importantly, what a trusted contact is not. The trusted contact can't make trades in the customer's account. I think that's one thing that customers kind of misunderstand. They can't make decisions about the customer's account. Being a trusted contact does not make them power of attorney, legal guardian, trustee or executor. It's really used in very limited circumstances. It's incredibly important firms get that message out. How do we get that message out? So, obviously we've been talking about Reg Notice 22-31, but we also collaborated with NASAA, with the SEC, on a campaign really to get that word out. So, we have a web page that provides details on how a trusted contact can help customers. We have a colorful infographic that reminds customers that firms can reach out to trusted contacts only in limited circumstances. We have a 45-second video that explains what a trusted contact is and is not, and why it's so important that customers provide one to their firms. So, we really hope that firms use those materials with their customers to dispel some of the misinformation that is out there.

10:17 - 10:27

Kaitlyn Kiernan: We have all that information on our website. We'll link to it in the show notes. Alicia, are there any other effective practices beyond the educational component that you want to share?

10:27 - 12:42

Alicia Goldin: So, part of educating customers is really about explaining the variety of benefits of naming a trusted contact. Although they can be critically important in a worst-case scenario involving financial exploitation or something like that, they've also proven really helpful in more mundane circumstances, so it's worth highlighting that range. For example, a customer may not be reachable due to travel—they're traveling internationally, and they haven't enabled an international plan on their mobile device. Or a customer may be known to be ill, and the trusted contact can be helpful to confirm their health status. But of course, in more serious circumstances, the rep may suspect diminished capacity or cognitive decline, and a trusted contact can be helpful in that circumstance. And of course, financial exploitation. If the rep suspects that there may be financial exploitation, the trusted contact can be a really valuable tool there as well. In that vein, the Reg Notice calls out effective practices that we've seen at firms. For example, some firms offer their reps a script or talking points to use in requesting trusted contact info and explaining what it means.

Some firms encourage their reps to discuss the benefits in one-on-one conversations with the customer, and that can be an opportunity to engage in beneficial conversations that help educate customers about fraudulent schemes, scams and exploitation. And some firms encourage information sharing so they have a range of real-world examples at their fingertips to explain to customers and to help make the value and the benefit of naming a trusted contact more tangible. If the firm emphasizes the importance to firm employees from supervisors to reps, to call center personnel to support staff, that can really be helpful too. And as well as taking concrete steps, training, and we've heard at least one firm that has been successful in getting trusted contacts where they've trained all customer-facing staff, including support staff and branch offices, who often have face to face interaction with customers. Some firms are using innovative practices such as creating target goals and publicizing the results among branch offices or regions to spur competitive instincts and provide added incentive for personnel to attempt to collect this important information.

12:42 - 12:56

Kaitlyn Kiernan: I will make my pledge to the two of you today that even though I'm a millennial who hates to pick up the phone, I will pick up the phone, call my broker and find out how to add this trusted contact today. But before we move on, is there any final thoughts on trusted contacts?

12:56 - 13:03

Alicia Goldin: I will just mention that the Reg Notice provides a lot more information on what we've just discussed and would encourage firms to read it.

13:04 - 13:12

Jim Wrona: Take stock of how you are approaching this and see if there are ways that you can make this a higher priority at your firm—a higher priority for your customers as well.

13:13 - 13:38

Kaitlyn Kiernan: Thanks, Alicia and Jim. So, to move on, Alicia, you just were mentioning suspected financial exploitation. So, I want to move on to another part of the broker-customer relationship, and that's how to handle these tricky situations where a financial professional notices something out of character and feels something just might not be right. Jim, can you give us some examples and tips for handling these kinds of issues?

13:38 - 15:05

Jim Wrona: Financial professionals are uniquely positioned. They have personal relationships with customers. They have the ability to observe behaviors, red flags, whether it's signs of diminished capacity or suspected financial exploitation. And with the tools that we have in place, they have the ability to follow up on those red flags by reaching out to a trusted contact and where there's reasonable belief of exploitation, the ability to place a temporary hold.

So, the issues of diminished capacity and financial exploitation are sometimes really intertwined as well. Some of the effective practices we've highlighted in guidance relating to protecting seniors relate to training on warning signs of potential exploitation and fraud, as well as diminished capacity—formal escalation procedures, implementing and training reps to use a comprehensive process to escalate issues related to seniors, including concerns about financial exploitation and diminished capacity.

Senior investor specialists, establishing specialized groups or individuals to handle situations involving elder abuse or diminished capacity. Centralizing outreach to a trusted contact, adult protective services, regulators, law enforcement as necessary. And these are also specialists that can support the reps in working directly with the customer. A lot of firms offer scripts or playbooks for their registered reps to use in these very difficult conversations with customers.

15:06 - 15:09

Kaitlyn Kiernan: What makes these conversations so difficult or tricky?

15:11 - 17:00

Alicia Goldin: So, obviously, these are sensitive topics to raise with a customer. And just as people have psychological tendencies that might affect their willingness to name a trusted contact, there are obviously psychological factors that might prevent someone from realizing or admitting that they're beginning to have cognitive impairment or that they're a victim of fraud. And sadly, we know that fraud often goes unreported. A 2013 FINRA Foundation paper highlighted just how underreported fraud can be. Although 11% of respondents lost money in a likely fraudulent activity, only 4% admitted to being a victim of fraud when asked directly. That's an estimated underreporting rate of over 60%. The small group of respondents who admitted that they did not report the fraud indicated that reporting it would not have made a difference. They did not know where to report it or they were just too embarrassed.

More recently, in June 2022, the Foundation, in collaboration with AARP Fraud Watch Network and Heart and Mind Strategies, put out a report called Blame and Shame in the Context of Financial Fraud, which focuses on a culture of victim blaming aimed at financial fraud victims. AARP and FINRA Foundation are engaging with firms, law enforcement and other stakeholders to drive long-term change and how victims of financial fraud are treated. One of the goals of this project is for victims to no longer hide in shame and instead to report the crime. I also wanted to mention that we recently had a Senior Investor Protection Conference, and Jim had a really interesting panel on the FINRA rules that we're talking about today and the observations shared by the panelists on how to navigate these tricky conversations actually inspired us to dig into these issues a bit more and to have this podcast.

17:01 - 17:31

Kaitlyn Kiernan: Awesome. Well, that's a good outcome from that panel. So, circling back to Rule 2165, which allows firms to place a temporary hold on a customer's account if there's a suspicion of exploitation of a senior or other vulnerable adult customer. What happens if the customer asks for, say, an unusual disbursement and the rep thinks something doesn't feel right here, they have a hunch. What can they do from there?

17:32 - 19:02

Alicia Goldin: One challenge in this situation is that the rep can be rattled by this. They may feel awkward or uncomfortable probing into the customer's request, or they might be inclined to jump right into action but because of their heightened state of awareness, may not be in the best position to evaluate the situation objectively. So, what we're hearing from some firms is that they tell their reps to tell the customer that they need to involve their team or legal and compliance to sort of give themselves a little bit more time. So, some examples: the rep can say to the customer, "Firm policy requires me to consult with legal and compliance and we'll have to follow up with some questions." They might say, "I'm going to gather some information and take this back to my team." That takes the pressure off the rep. We've heard this described as creating muscle memory so that their initial instinct is to hit the brakes a little bit. In fact, some firms set expectations early in a relationship about these types of things.

They might tell the customer that certain types of transactions have to go through additional steps internally and that they should expect delays. We have heard that if a customer objects too strongly to a delay, that can actually be a red flag that the customer is under some sort of pressure as part of a scam. We've also heard some firms have policies where they require at least two, and sometimes more, individuals to participate on a follow up call. And sometimes they're encouraging these conversations to occur in person or in a video call.

19:03 - 20:13

Jim Wrona: One of the challenges with the hold is getting enough information to support that reasonable belief that financial exploitation is occurring. And this is an area where, again, the trusted contact can be valuable. And I have to say, particularly when we're talking about romance scams, having a trusted contact, having another person as an ally to help convince the customer that they are being victimized is really, really important. In other instances, a trusted contact can be helpful on concerns around diminished capacity. And we heard a story the other day about a firm that suspected a customer was suffering from diminished capacity. It's a really, really difficult situation for any firm to be in. They reached out to the trusted contact, who was the niece, and she was able to get her uncle the help that he needed. And it turned out that, in fact, he was suffering from dementia, and it stopped some inappropriate trading activity that he was starting to engage in. They fold into one another, the trusted contact, the hold provision. These are all really good tools that we hope firms are aware of and are using.

20:14 - 20:43

Kaitlyn Kiernan: Thanks, Jim. So, regardless of whether there's a trusted contact on the account, the rep or firm staff, they're going to be hopefully engaging with the customer as well. So, I imagine it's helpful and important for firms to train their staff and empower their staff to ask the right types of questions to either rule out an issue or to support the reasonable belief of exploitation. So, what are some of the ways that firms are helping to train their staff in this way?

20:43 - 27:02

Jim Wrona: One firm hired a retired New York detective to help train reps on how to ask the right questions. I think, as previously mentioned, a lot of firms have designated a particular person or group that specialize in handling these types of matters and they provide training or, as Alicia noted, sometimes participate in the conversations with customers. So, some quick takeaways from talking with these folks. First, the importance of asking second- and third- level follow up questions when you suspect that there's an unusual request for a disbursement or for a transaction. And a lot of the customers who are the victims of financial exploitation are coached by the criminals. And so those follow up questions can sometimes break it down for you. A common example would be, "Oh, well, this unusual $100,000 disbursement request is to pay for the grandchild's college." And so, the follow up question is, "Oh, that's terrific. Where are they going to college?" Do they know the answer to that? Do they know the answer top of mind? Maybe they do. Maybe they have been coached to say, yes, they're going to state university.

So, then follow up, "what are they planning to major in?" So, there's a series of questions depending on the responses you get, they can kind of dig into, is this really legitimate? And what we've heard from firms is that there's oftentimes this pause when they start asking these questions and then it's, "Well, I'm not supposed to tell you this, but I met someone online and he needs money or she needs money," "I won the lottery, and this is to prepay the taxes, but they didn't want me to tell anybody." And once that happens, then you can have that next stage conversation that, "We think that this might be a scam, let's work with you."

Another thing that firms have told us is it's important to repeat facts back to customers, and particularly when there's an absurd or outlandish explanation, repeating it back can really prompt the customer to recognize on their own that something funny is going on.

Ask about the potential need for future spending. There's a number of scams that keep coming back to the well, and it results in a pattern of withdrawals. So, the customer may respond that, hey, this is a one-time disbursement to purchase a car, to fix a roof, to buy a house, to pay for a grandchild's college tuition, whatever they've been coached to say. But if the customer then subsequently comes back with another unusual disbursement request, you can remind the customer about that earlier conversation. And that sometimes leads to an awareness that something funny is going on. Again, it's obviously also more evidence of potential financial exploitation to support a hold that you might have to place on the account or on the disbursement request.

And another thing that they mentioned is that, without victim blaming, because that is something we absolutely want to stay away from, appeal to the customers better angels. And so, some firms have pointed out to customers, for instance, that they're particularly careful about potential financial scams, not only out of concern for the customers, but also because criminals often use money gained from scams to harm others. It's used for sex trafficking; it's used for drug cartels to support terrorist organizations. And some firms have had a lot of success with that approach. Customers may not be thinking clearly about their own self-interest, but they don't want to inadvertently be supporting nefarious activity or harming others.

Another point that firms made is the importance of gathering documentation, which can often be used to dispel that something is being done for a legitimate purpose.

So, one example I was given was in romance scams—try to get a picture. So, they're talking to the customer and it's "this person that I'm madly in love with needs help with his or her small business," or "needs travel money so we can get together and get married." And you say, "Oh, that's great, you know, I'm so happy for you. Hey, do you have a picture?" And they'll oftentimes be able to get a picture and then they do a reverse image search, and they can see it's a stock photo or that it's a photoshopped image. One firm said that there were multiple instances where there was an image used of a famous actor. Now, that may become more difficult with artificial intelligence, but it is something that firms have been using effectively, or if there's any other documentation, you can get contracts, wills, any other paperwork.

I was just talking to a firm the other day and they said that they suspected there was financial exploitation going on. The money was needed for a business deal that this customer was purportedly engaged in. They got a copy of the contract which was supposedly with this one company. They called the company; it was a legitimate company. They sent a picture of the contract. The company said, "Nope, that's not us. I mean, that's our name, but that's not our contract." And so, it was very quickly then unraveled. Another technique that some firms will use, particularly if it's a large disbursement request, is to ask the customer if they can speak to the customer's lawyer or CPA, just to help make sure that the transaction goes through the way the customer wants and that it's being used for what they expect it's being used for. That's another ally that can help to dispel that this is being used for legitimate purposes.

It's important to perform a post-mortem assessment when things go wrong, learn what you can do better. But what firms told us is that it's also really, really important to celebrate success stories. So, when reps or your specialized unit is having these really difficult conversations and they uncover financial fraud and they help the customer, that those should be celebrated. Those are some of the things we heard from firms that have been effective.

27:02 - 27:24

Kaitlyn Kiernan: That's really interesting. Thanks, Jim. Not every firm can have a retired detective on staff, but a lot of those examples you gave are really just basic follow up questions. It's not feeling like an interrogation that you might expect on some detective show on TV. Is there any other resources or interview techniques besides the tips Jim shared that may be a good resource for firms here?

27:25 - 28:56

Alicia Goldin: There's some practical guidance that can be gleaned from public sources that address interview techniques, including, among others, tips related to tone of voice, nonverbal communication, use of follow up questions, as Jim talked about, and strategic pauses. One example is a resource guide published by the International Association of Chiefs of Police. It's called Successful Trauma-Informed Victim Interviewing. And although the context of those interviews is different, some of the principles could be helpful to keep in mind. Phrasing of questions is important. So, depending on how a question is asked, it might be perceived by a victim as blaming them for their actions or for what they may be unable to recall. So, using open ended questions and requests gives the person the opportunity to share more information about what they are able to recall.

And coming back to the report on blame and shame that I mentioned, there are some helpful themes in this report that are worth keeping in mind. In particular, one theme is to use alternative language to describe victims, perpetrators and the crime itself. Shifting away from generic terms like scammer and fraudster, which can downplay the seriousness, is a helpful tip and being careful in how you frame the fraud. So, it was the criminal that stole the victim's money and not the victim that was duped. Another tip is humanizing the emotional impact of fraud, and this involves portraying relatable victims and relatable circumstances and just making it more personal.

28:57 - 29:04

Kaitlyn Kiernan: Coming back to the broader topic of senior investor protection, are there any other efforts FINRA is making that are worth highlighting today?

29:04 - 30:38

Jim Wrona: In addition to the rules we've already discussed, we also adopted Rule 3241, which limits reps from being named a beneficiary or holding positions of trust for or on behalf of customers. FINRA has also put out a lot of materials regarding senior investor protection issues, and an important goal for those materials is to highlight the variety of effective practices that we see through our examinations and other outreach efforts. Look, firms can see what other firms are doing and think about how to improve their own procedures. So, it's borrowing ideas from their peers and some examples of those materials.

We also put out a report called Protecting Senior Investors 2015 to 2020, that highlights FINRA's initiatives including the impact of the Senior Helpline, which is also another important tool in this fight against elder financial abuse. And that report also shared effective practices more recently put out FINRA's 2023 Report on Examination and Risk Monitoring Programs. And there's a section in there that includes findings and effective practices related to all the rules we've talked about today. And then there's a FINRA, SEC and NASAA co-hosted webinar relating to the Senior Safe Act. And for those who don't know, the Senior Safe Act provides immunity from liability for reporting potential exploitation of a senior citizen. Those are some other resources. We have a dedicated senior investor webpage. So, a lot of those resources will be available there.

30:38 - 30:46

Kaitlyn Kiernan: Great. Thanks, Jim. So, just to wrap up, are there any final thoughts or key messages you want our listeners to walk away with today?

30:47 - 31:18

Alicia Goldin: The tone from the top matters. So, emphasizing the importance of these rules, the importance of collecting trusted contact information, the importance of being well-prepared to handle difficult conversations is really important. But as we've talked about, these issues play out in the interpersonal relationships between reps and their customers. So, this is an area for reps to think about and to be prepared to serve their customers in the best way possible and to be sensitive and educated and just well-equipped to help them.

31:19 - 32:13

Jim Wrona: The broker-dealer industry as a whole has been a thought leader on protecting seniors. And that's something for all of us to be proud of. And when I say all of us, I mean it. Broker-dealers, regulators, investor protection groups have all come together to make this happen. But there's still more work to be done and starting with getting better numbers when it comes to trusted contact info, 38% positive response rate is too low. A trusted contact will be vital when you have a customer that's a victim of financial abuse or that might be suffering from diminished capacity. So, don't take my word for it. Talk to your peers who have been in that situation. Trust me, they're going to tell you that it was absolutely key to resolving the matter. And for all of the C-suite executives who are listening, please make the protection of senior investors a priority. The tone from the top that was mentioned is so important. So, let's keep leading the way.

32:14 - 32:45

Kaitlyn Kiernan: Well, that's it for today's episode. Alicia and Jim, thank you so much for joining me to provide an update on FINRA's important senior investor protection efforts for our listeners. If you have any questions on today's episode or ideas for future episodes, you can email us at [email protected]. And if you don't already, be sure to subscribe to FINRA Unscripted wherever you listen to podcasts so you can always stay up to date on our latest. Today's episode was produced by me, Kaitlyn Kiernan, engineered by John Williams and coordinated by Hannah Krobock. Till next time.

32:45 – 32:50

Outro Music

32:50 - 33:18

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